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From:
To }Owain Draper
Ce: Andrew Parsons } c _
Subject: RE: Defence and Compare [BD-4A.FID26896945]
Date: Fri, 14 Jul 2017 14:36:39 +0000
Importance: Normal
Attachments: 115 _Bates_draft_Defence.docx
Inline-Images: image001 jpg; image002.png; image003.png; image004.png
Thanks for the clarification, Amy.
I have whizzed through the draft and here are my suggestions. Like you, I have generally steered clear of trying to
correct and complete the innumerable internal para refs in the pleading — I presume that will come later, after the text
has all been finalised.
As you will see, there are a few points where I have tried to explain the changes I’ve made because I’m concerned I
might have got the wrong end of the stick, for example para 57(3). I’ve also highlighted some points that I feel uneasy
about and which it might be a good idea to talk about, for example paragraphs 46(4) and 56(1).
Best wishes,
Tony
From: Amy Prime!__
Sent: 14 July 2017 14:34
To: Anthony de Garr Robinson
Cc: Andrew Parsons! : GRO
Subject: RE: Defence and Compare [BD-4A.FID26896945]
Owain Draper: GRO
Tony
None in particular, there aren't that many amendments so please feel free to review all of those highlighted in the
compare.
There are comments in the world version of the defence which explain some of the amendments.
Amy
Amy Prime
Solicitor
Bond Dickinson LLP
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From: Anthony de Garr Robinson
Sent: 14 July 2017 14:24
To: Amy Prime; Owain Draper
Cc: Andrew Parsons
Subject: RE: Defence and Compare [BD-4A.FID26896945]
Thanks, Amy.
I’ve promised Andy not to read the whole pleading, but I will look at the changes to see if I have difficulties with any
of them. Is there anything you would like me particularly to look at?
Tony
From: Amy Prime! GRO 4
Sent: 14 July 2017 13:55 ee
To: Owain Drap‘ {o) ; Anthony de Garr Robinson
Cc: Andrew Parsons! GRO. j
Subject: Defence and Compare [BD-4A.FID26896945]
Tony
Please see attached the current version of the Defence (with the exception of the changes to the Suspense Account
rider which Andy has just sent). Also attached is a comparison to version 112 of the Defence which you circulated on
Wednesday.
Many thanks
Amy
Amy Prime
Solicitor
Bond Dickinson LLP
A new-breed of Goud Dicliager.
transatlantic law firm
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